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Dutch Tax Authority Explains Payments for Software Distribution Licenses Not Royalties Under Tax Treaty with South Korea

|Treaty Development|Netherlands-South Korea
Netherlands-South Korea

The Dutch tax authority has published a response to a question on whether payments for software distribution licenses would be considered royalties under Article 12 (Royalties) of the 1978 income tax treaty with South Korea and subject to withholding tax in South Korea. The question concerned a Dutch software company (X BV), which licensed software to a distributor in South Korea. The distribu…

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